Public Comment on US EPA’s Model Civil Rights Program Open until February 17, 2012

In April 2011, U.S. EPA Administrator Lisa P. Jackson, whose blog you can follow here, formed a Civil Rights Executive Committee to review an independent report, authored by the firm, Deloitte Consulting, LLP, and provide recommendations for strengthening EPA’s civil rights program.  The Deloitte Report identified, among others, the following shortcomings in the EPA’s administration of its Title VI external discrimination complaints and compliance program:

1. “Due to this complexity, the Title VI program has struggled to develop a consistent framework to analyze complaints [of discrimination], resulting in a lengthy and time-consuming effort to evaluate the complaints and once accepted, to adequately investigate the cases.”  See, Deloitte Report, at pg. 25.
2. “EPA has not been able to develop a repeatable complaint resolution process and framework” such that the “[Office of Civil Rights] lacks finalized operational documents to govern the program’s internal functions, or to communicate meaningful guidance to external stakeholders.”  See, Deloitte Report, at pg. 25.
3. EPA’s Office of Civil Rights “program staff’s competencies are inconsistent and/or misaligned with the highly technical nature of complex Title VI complaints investigations.”  See, Deloitte Report, at pg. 26.

The recommendations in the Deloitte Report prompted EPA to draft its own Recommendations for Developing a Model Civil Rights Program at the Environmental Protection Agency.  EPA’s proposed recommendations for improving it’s Title VI complaint and compliance program can be found at pp. 12-13 of the draft recommendations.  The Model Civil Rights Program is Attachment 2 to the draft recommendations.  Those recommendations are now available for public review and comment.

Environmental Justice advocates have, for the first time in a long time, an opportunity to contribute to a meaningful internal review and restructuring of the way in which U.S. EPA administers its non-discrimination programs and enforces non-discrimination laws.  Your comments may be sent to Administrator Jackson at jackson.lisap@epa.gov and are due by February 17, 2012.  Let your voice be heard!